Dear Environmental Protection Authority,

The government's outlet Orillion sell brodifacoum products. My questions concern one of their products: Pestoff Rodent bait 20R, which is normally used for aerial applications.

1. Brodifacoum products sold world-wide states that it is hazardous to aquatic life on their labels/Code of Practices. This is omitted from this New Zealand cautionary warning label and Code of Practice. Why is that?

a) Please provide relevant documentation that explains the decision to allow Pestoff 20R being placed into New Zealand waterways/riverbeds and why this is omitted from the NZ label.
b) Please provide documents that highlights the public health and safety issues of brodifacoum under OP 63.
c) MPI signs off on exemptions to aerial application. Should not the same general public health and safety issues apply as under OP 63? Please provide documents that explain the reasons that the OP 63 guidelines of public health and safety are viewed as irrelevant under the government's new amendment as it exempts OP 63 guidelines for exactly the same product, brodifaocum Pestoff 20R?

2. "Do not breathe dust" is stated on the NZ brodifacoum cautionary label. What distance does EPA think is sufficient during an aerial application to ensure public safety? For example 5-100 meters from a housing area? Please provide documentation that clarifies/justifies this warning statement. And who would be the reinforcement agency for any immediate breaches?

3. Code of Practice: "Pest proof fences must be of a design and construction which has been tested and proven to be fully effective in preventing access to the Specified Area by all farm livestock and target pests present. Such fences must be able to be maintained in a pest proof state."
a) Who are qualified to ensure these standards?
b) What agency enforces that the above regulation are being met?
c) Please provide your guidelines/documentation as of who these people/agencies are?

Photos of old and more current slips and slumps can be provided provided of the Nelson Mainland fenced in area as per Code of Practice. One example is from an Nelson Mail article 24/02/2016 (http://www.stuff.co.nz/nelson-mail/news/...).

I am looking forward to your reply.

Yours sincerely,

Helen Black

File Ref: ENQ-32428-Z4Q8P1 Dr Fiona Thomson-Carter

Thank you for your reply. I would appreciate some further clarifications.

1. "The label for Pestoff Rodent Bait 20R includes its hazard classification ‘9.1D’, meaning that the substance is slightly harmful to the aquatic environment. As Pestoff is a vertebrate toxic agent, the Transfer Notice and controls focused the labeling requirements on the harm to vertebrates."

The New Zealand hazard classification differs vastly from the hazard classifications in the US, Canada, Europe and the World Health Organisation (comments and links supplied below). Are potential risks to waterways minimised in New Zealand? What scientific studies does EPA base its classification '9.1D' on? Does it help the environment as a whole to focus the label requirements on what one wants to get rid off?

2. The majority of dust particles in the atmosphere are not visible to the eye. A moving helicopter dropping toxic baits close to a housing area (approximately 30 meters) cannot be compared to a sheltered workshop or a fenced off loading area. Are potential risks to public health minimised in New Zealand? What scientific studies has been done and what is the rational behind to exclude people who live close to areas that are aerially applied with brodifaocum baits from 'Do not breath in dust'?

US/Canada: Brodifacoum: Hazard Identification:
Highly toxic by inhalation; Potential Health Effects: Inhalation: May be fatal if inhaled. May cause respiratory tract irritation.
Acute aquatic toxicity (Category 1)
Other adverse effects: An environmental hazard cannot be excluded in the event of unprofessional handling or disposal. Very toxic to aquatic life. Hazardous to the aquatic environment, long-term hazard.
http://datasheets.scbt.com/sc-239414.pdf
Point 12: https://pubchem.ncbi.nlm.nih.gov/compoun...

Europe:
Hazard statement codes: Very toxic to aquatic life with long lasting effects.
With regards to Environment: Aquatic acute; Aquatic chronic.
https://circabc.europa.eu/sd/a/d88b968d-...

WHO: Brodifacoum is of high acute toxicity to birds, fish, aquatic invertebrates and algae.
http://who.int/whopes/quality/en/Brodifa...

I am looking forward to have this clarified.

Yours sincerely,

Helen Black